CHEMTURA CANADA PROGRESS REPORT - MAY 2016

Technically Chemtura failed to achieve their targeted pumping rates in May due to pumping well W3. It was a very nominal shortfall and in fact their pumping rates have been as high as they've ever been for some time now. Of course this is all relevant when nearly four years ago under pressure from CPAC they finally admitted that their off-site remediation of the Elmira Aquifers wasn't going to do the job on time. Therefore they promised to both TRIPLE the off-site pumping AND to do source removal of some off-site hot spots with In Situ Chemical Oxidation (ISCO). That tripling has since been reduced to a promise to DOUBLE the off-site pumping. They bungled their pilot tests of ISCO and have been so exposed by Dr. Jackson of TAG. I am currently unaware of any further ISCO testing on their part. Lots of work allegedly being done towards increased pumping but to date it that pumping is not a reality. Is it for real or simply more of their bluster and bullshit?

Table A.1 as usual is woefully uninformative. While there are multiple concentrations at various stages of the groundwater treatment (on & off-site) for Ammonia, there are but one for chlorobenzene, Toluene, Benzothiazole and Carboxin. Nothing at all for NDMA. If you're going to produce this Table then at least fill in the results for us to see how you are doing.

Table A.3 has the results for a number of upper aquifer wells relevant to the containment and treatment system. The results for chlorobenzene, tolune and Base/Nuetral compounds on their site are as horrific as always.

MISA results are still disappointing in that this Municipal/Industrial Strategy for Abatement (MISA) is more about monitoring pollution than in actually stopping it. Several of the outfalls from Chemtura's on-site storm sewers still discharge low levels of solvents and pesticides such as Lindane, Benzothiazole and Carboxin directly into the Canagagigue Creek.

As far as direct measuring in the creek at the parts per billion level, while the creek is much improved, nevertheless there is still a slightly higher downstream average of tolune (over 37 samples) than upstream. This is hardly surprising. My thought is how many Chemtura chemicals would be detected in the creek at lower method detection limits?

Table D.1 records NAPL or Non-Aqueous Phase Liquids in various wells on site. These include both LNAPLS and DNAPLS otherwise known as Light or Dense NAPLS. THe LNAPLS are still measured floating on the water table in places at nearly half a metre thick. That is disgusting and Chemtura's assurances that they can do nothing about it is bullshit also about half a metre thick. DNAPLS are being found still near their main tank farm and also routinely in the TPW2 area where they've been present for decades. DNAPLs are in numerous areas on their site but are being left there thanks to the October 1991 sweetheart deal between Uniroyal Chemical and the Ontario Ministry of the Environment.

And so it remains.